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PHILIP A. TALBERT
United States Attorney
DEBORAH LEE STACHEL
Regional Chief Counsel, Region IX
Social Security Administration
ADAM LAZAR, CSBN 237485
Special Assistant United States Attorney
160 Spear Street, Suite 800
San Francisco, California 94105
Telephone: (415) 268-5601
Facsimile: (415) 744-0134
E-Mail: adam.lazar@ssa.gov
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Attorneys for Defendant
UNITED STATES DISTRICT COURT
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EASTERN DISTRICT OF CALIFORNIA
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SACRAMENTO DIVISION
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TRACY HIMES,
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Plaintiff,
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vs.
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NANCY A. BERRYHILL
Acting Commissioner of Social Security,
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Case No.: 2:17-cv-00403-AC
JOINT STUPULATION AND
[PROPOSED] ORDER FOR EXTENSION
OF TIME
Defendant.
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Defendant Nancy A. Berryhill, Acting Commissioner of Social Security (“Defendant”)
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respectfully requests that the Court extend the time for Defendant to file her Opposition to
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Plaintiff’s Motion for Summary Judgment, originally due on August 7, 2017, by 30 days,
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through and including Wednesday, September 6, 2017. This is the Commissioner’s first request
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for an extension of time in this matter.
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An extension of time is needed in order to prepare Defendant’s opposition because
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counsel has three oppositions to motions for summary judgment due this next week, and is
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further responsible for a major discovery production due next week. This request is made in
Stipulation for Extension of Time; 2:17-cv-00403-AC
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good faith with no intention to unduly delay the proceedings. Counsel’s office conferred with
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Plaintiff’s counsel, who had no objection to this request, on August 3, 2017.
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Respectfully submitted,
Dated: August 4, 2017
PHILIP A. TALBERT
United States Attorney
DEBORAH LEE STACHEL
Regional Chief Counsel, Region IX
Social Security Administration
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By:
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/s/ Adam Lazar
ADAM LAZAR
Special Assistant U.S. Attorney
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Attorneys for Defendant
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/s/ Richard Whitaker*
RICHARD A. WHITAKER
(*by email authorization)
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Attorney for Plaintiff
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Dated: August 4, 2017
By:
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ORDER
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IT IS SO ORDERED.
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Date: August 7, 2017
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Stipulation for Extension of Time; 2:17-cv-00403-AC
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